PUBLIC DISCLOSURE July 21, 2014 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION The St. Henry Bank RSSD # 568126 231 East Main Street St. Henry, OH 45883 Federal Reserve Bank of Cleveland P.O. Box 6387 Cleveland, OH 44101-1387 NOTE: This document is an evaluation of this institution's record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operation of the institution. This evaluation is not, nor should it be construed as, an assessment of the financial condition of this institution. The rating assigned to this institution does not represent an analysis, conclusion or opinion of the federal financial supervisory agency concerning the safety and soundness of this financial institution.
TABLE OF CONTENTS Institution s CRA Rating...1 Scope of Examination...2 Description of Institution...4 Description of Assessment Area...6 Conclusions with Respect to Performance Criteria...13 Appendix A: Assessment Area Map...20 Appendix B: Lending Tables...21 Appendix C: Glossary of Terms...23 Table of Contents
INSTITUTION'S CRA RATING: This institution is rated Satisfactory. The major factors and criteria contributing to this rating include: The loan-to-deposit ratio is reasonable (considering seasonal variations and taking into account lending-related activities) given the institution s size, financial condition, and assessment area credit needs; A majority of loans and other lending-related activities are made in the assessment area; The distributions of loans to borrowers reflects a reasonable penetration among individuals of different income levels (including low- and moderate-income); The distributions of loans to businesses reflects a reasonable penetration among businesses of different revenue sizes given the demographics of the assessment areas; and, There were no CRA-related complaints filed against the bank since the previous CRA examination. The previous examination conducted June 1, 2010, resulted in a Satisfactory performance rating. 1
SCOPE OF EXAMINATION The St. Henry Bank (St. Henry) Community Reinvestment Act (CRA) performance was evaluated using the interagency small bank procedures under Regulation BB. The bank s CRA performance included lending data from January 1, 2013 to December 31, 2013. The loan products evaluated included consumer, residential mortgage, small business (commercial) and small farm lending. The following table and charts illustrate the volume and distribution of loans originated during the evaluation period. Loan Type Number of Loans Dollar Amount of Loans (000s) Residential 169 25,438 Consumer 206 1,975 Small Business 104 35,234 Small Farm 127 18,575 Total 606 81,222 Based on total loan volume by number and dollar amount and the composition of the loan portfolio, residential lending received the most weight, followed by consumer, small business, and small farm loans, which were all weighted equally. The bank s assessment area for CRA purposes is comprised of one assessment area that received a full-scope review. The size and financial condition of the institution, lending opportunities in the assessment area, and competition with other financial institutions were also considered in the bank s performance context. One community contact interview was conducted to provide context to the demographic and economic characteristics of the assessment area in which the bank operates. 2
Although both geographic and borrower distributions were evaluated in order to determine the bank s overall CRA performance, only St. Henry s borrower distribution is discussed in this analysis as the bank s assessment area consists of only middle-income and upper-income census tracts and there are no distressed or underserved middle-income tracts. Additionally, it is noted that lending was performed in all of the bank s census tracts. 3
DESCRIPTION OF INSTITUTION St. Henry is an independently owned community bank located in St. Henry, Ohio. According to the March 31, 2014 Uniform Bank Performance Report (UBPR), St. Henry reported approximately $263.9 million in assets, a 33.4% increase in total assets since the previous CRA evaluation. St. Henry s main office is located in an upper-income tract in St. Henry. The bank has two additional branches, both located in upper-income tracts: one in St. Henry and the other in Maria Stein. All three locations are located in Mercer County and have full-service Automatic Teller Machines (ATMs). St. Henry is a full-service retail bank offering deposit accounts; residential mortgages; consumer, commercial and agricultural loans; small business loans; and small farm loans. St. Henry has not opened or closed any branch offices or ATMs. Since the previous evaluation, St. Henry delineated its assessment area to now include the entirety of Mercer County. Additional census tracts from Auglaize and Shelby Counties were also added to the bank s assessment area. According to the March 31, 2014 UBPR, St. Henry s loan portfolio accounts for approximately $125 million. The following chart represents the bank s loan portfolio as of December 31, 2013. COMPOSITION OF LOAN PORTFOLIO 12/31/2013 12/31/2012 12/31/2011 Loan Type $ (000s) Percent $ (000s) Percent $ (000s) Percent Construction and Development 3,109 2.5% 2,669 2.3% 2,066 1.8% Secured by One- to Four- Family Dwellings 39,953 32.7% 40,495 34.5% 44,748 39.5% Other Real Estate: Farmland 29,913 24.5% 28,263 24.1% 23,201 20.5% Other Real Estate: Multifamily 1,640 1.3% 1,692 1.4% 1,732 1.5% Other Real Estate: Nonfarm nonresidential 30,047 24.6% 29,639 25.3% 25,756 22.7% Commercial and Industrial 9,913 8.1% 7,543 6.4% 9,078 8.0% Loans to Individuals 3,113 2.5% 2,989 2.5% 3,309 2.9% Agricultural Loans 4,487 3.7% 4,004 3.4% 3,415 3.0% Total $122,175 100.00% $117,294 100.00% $113,305 100.00% * This table does not include the entire loan portfolio. Specifically, it excludes loans to depository institutions, bankers acceptances, lease financing receivables, obligations of state and political subdivisions, and other loans that do not meet any other category. Contra assets are also not included in this table. 4
Loan Portfolio as of 12/31/2013 (%) 2.5 3.7 2.5 Construction and Development 24.6 8.1 32.7 Secured by One- to Four- Family Dwellings Other Real Estate: Farmland Other Real Estate: Multifamily Other Real Estate: Nonfarm nonresidential Commercial and Industrial Loans to Individuals 1.3 Agricultural Loans 24.5 As of March 31, 2014, St. Henry s investment portfolio was approximately $116.5 million. The investment portfolio consists of U.S Treasury and Agencies securities (59.9%), municipal securities (36.9%), interest-bearing bank balances (3.0%), and all other securities (.22%). There are no legal or financial constraints preventing St. Henry from meeting the credit needs of its assessment area consistent with its asset size, business strategy, resources, and local economy. 5
DESCRIPTION OF ASSESSMENT AREA IN NON-METROPOLITAN AREA IN WESTERN OHIO St. Henry has one assessment area in the Western portion of Ohio. The assessment area is comprised of the entirety of Mercer County and portions of Shelby, Auglaize, and Darke Counties. Mercer County is considered a predominantly agricultural area. St. Henry took a total of nine census tracts, six of which are located in middle-income tracts and three in upper-income tracts. Celina is the largest city and the county seat. The overall population had an estimate of 40,784, according to the U.S. Census Bureau in 2013. Shelby County is also primarily agricultural. St. Henry has taken a total of three census tracts, one of which is located in a middle-income tract and two in upper-income tracts. Sydney is the largest city and the county seat. The overall population had an estimate of 49,192, according to the U.S. Census Bureau in 2013. Darke County is also primarily agricultural. St. Henry has taken one census tract, which is located in an upper-income tract. Greenville is the largest city and county seat. The overall population had an estimate of 52,376, according to the U.S. Census Bureau in 2013. Auglaize County is also primarily agricultural. The bank has taken a total of five census tracts, two located in middle-income tracts and three in upper-income tracts. Wapakoneta is considered the largest city and county seat. The overall population had an estimate of 45,920, according to the U.S. Census Bureau in 2013. Overall, there are a total of 18 census tracts that consist of nine middle-income and nine upperincome tracts. As previously stated, the assessment area is predominantly agricultural and located in middle and upper-income tracts. As of June 30, 2013, the Federal Deposit Insurance Corporation s (FDIC) Market Share Report 1 ranks St. Henry ninth out of 23 institutions in the assessment area with a market share of approximately 5.6%. The following table shows the deposit market share for the top ten financial institutions in the assessment area. 1 FDIC Summary of Deposits, www.fdic.gov 6
# Financial Institution Deposit Market Share 1 U.S. Bank, National Association 10.04% 2 JPMorgan Chase Bank, National Association 9.76% 3 The Peoples Bank Co. 9.73% 4 First Financial Bank, National Association 8.96% 5 Greenville National Bank 8.40% 6 The Park National Bank 8.35% 7 Minster Bank 7.91% 8 First National Bank in New Bremen 5.84% 9 The St. Henry Bank 5.61% 10 Fifth Third Bank 4.43% A community contact interview was conducted with a local community and economic development leader serving Mercer County to provide additional information regarding the credit needs of the local community and context to the demographic and economic characteristics. According to the community contact, the economy has remained stable, as the area is largely agricultural and was not affected by the negative trend within the residential market. However, he mentioned an upward trend in the housing market and noted an opportunity for banks to provide housing or financial education. Lastly, he indicated local bankers have a high level of involvement within the community through local donations and marketing efforts. Population According to data provided by the 2010 U.S. Census report, the total population living in St. Henry s assessment area is 79,209. The following table depicts the 2010 and estimated 2013 populations of the four counties within the bank s assessment area, as well as the estimated population change. 2 County 2010 Population 2013 Population Population Percent Change Auglaize 45,937 45,920 0.0% Darke 52,957 42,376-20.0% Mercer 40,765 40,784 0.0% Shelby 49,353 49,192-0.3% Total 189,012 178,272 2 American Fact Finder, http://factfinder2.census.gov 7
The population by age is distributed as follows: As the chart indicates, 27.1% of the population within the assessment area is 17 and younger, while approximately 58.3% of the population is between the ages of 18 and 64, which is the legal age to enter into a contract and more likely to have credit needs. There are no low- or moderate-income census tracts in the assessment area. Of the population in the assessment area, 49.6% live in upper-income census tracts and 50.4% live in middle-income census tracts. Income Characteristics According to the 2010 U.S. Census data, there are 30,027 households in the assessment area, of which 21,898 (72.9%) are families. Of these families, 11.9% are low-, 15.8% are moderate-, 22.7% are middle-, and 49.5% are upper-income. Additionally, 5.9% of families in the assessment area live below the poverty level, compared to Ohio s rate of 10.3%. According to 2012 estimates, the percentage of people living below the poverty level in Auglaize County is 9.7%; Darke County, 12.6%; Mercer County, 9.4%; and Shelby 10.2%; all of which are below Ohio at 16.2%. 3 The median family income for the assessment area is $61,604, which is higher than the median income for Ohio at $59,680. Based on 2013 HUD data, the median family income decreased to $53,000. 4 3 U.S. Department of Agriculture, www.ers.usda.gov/data-products/county-level-data-sets/poverty 4 Department of Housing and Urban Development, www.huduser.org/portal/datasets/il.html 8
Labor, Employment, and Economic Characteristic The following table shows the top four employment sectors (by number of persons employed in the county) and some of the major employers in the assessment area. 5 County Primary Employment Sectors Major Employers Auglaize Manufacturing/Agriculture; Trade, Transportation, and Utilities; Education and Health Services; Leisure and Hospitality; and Local Government American Trim, Crown Equipment Corp., Danone Group/Dannon Co., Grand Lake Health System, Hitachi Metals/AAP St. Mary s Corp., Minster Machine Co., Setex Inc., St. Mary s City Schools, Veyance Technologies Inc., and Darke Mercer Shelby Construction; Trade, Transportation, and Utilities; Professional and Business Services; and Other Services Construction; Trade, Transportation, and Utilities; Financial Services; and Other Services Manufacturing/Agriculture; Trade, Transportation, and Utilities; Professional and Business Services; Leisure and Hospitality; and Local Government Wapakoneta City Schools Brethren Retirement Community, Dick Lavy Trucking, FRAM Group Operations LLC, Greenville City Schools, Midmark Corp., Moriroku Co./Greenville Technology, Wal-Mart Stores Inc., Wayne HeathCare, Whirlpool Corp./KitchenAid Awardcraft, Celina Aluminum Precision Technology, Celina City Schools, Cooper Farms Inc., Crown Equipment Corp., Fort Recovery industries Inc., Mercer Health, Pax Machine Works, Reynolds & Reynolds Co., WorkflowOne Emerson Climate Technologies, Freshway Foods, Honda Motor Co. Ltd., Nippon Konpo Unyu/NK Parts Industries, Plastipak Packaging Inc., Shelby County Government, Sidney City Schools, Superior Metal Products/Am Trim, Thor Industries/Airstream, Wal-Mart Stores Inc., Wilson Memorial Hospital One of the major sectors in the assessment area is manufacturing/agriculture, followed by construction and trade. Within those sectors, major employers include Cooper Farms and American Trim. As previously mentioned, a community contact serving Mercer County was interviewed and stated that Mercer County was considered first in agriculture in Ohio. The following chart compares the 2013 and 2014 (not seasonally adjusted) unemployment rates in Auglaize, Darke, Mercer, and Shelby Counties. 5 Ohio Country Profiles, Ohio Office of Policy, Research and Strategic Planning, http://development.ohio.gov/reports/reports_countytrends_map.htm 9
As indicated above, the unemployment rate in all counties has decreased and is slightly below Ohio s unemployment rate. Per the community contact, the economy has been stable throughout the years, even during the recession, and believes it is mostly due to the agricultural and small manufacturing industries that were not heavily impacted by the economy. Housing Characteristics Based on 2010 U.S. Census data, there are 33,056 total housing units within the assessment area. Of these units, 73.6% are owner-occupied, 17.2% are rental units, and 9.2% are vacant. Single family units account for 84.5% of the units and 2-4 family units account for 7.5%. All housing units are located in middle- and upper-income census tracts. The median age of housing stock in the assessment area is 45 years, which compares to the median age of housing stock for Ohio at 44 years. Within St. Henry s assessment area, the median age of housing was 47 years in middle-income tracts and 42 years in upper-income tracts. The median housing value in the assessment area is $131,699, with an affordability ratio of 39.3%. The higher the affordability ratio, the more affordable the home is considered. The housing affordability ratio is calculated by dividing the median household income by the median housing value. The housing stock in the assessment area is slightly more affordable than Ohio overall, which has an affordability ratio of 34.7%. Of the 24,327 owner occupied housing units in the assessment area, approximately 31.9% are valued under $100,000, 26.9% are valued at $100,000-149,999, and 41.2% are valued at $150,000 or more. 10
Based on the median family income for the assessment area ($61,604), approximately 32.1% of the homes valued up to $100,412 would be affordable for low-income individuals and 63.2% of the homes valued up to $160,660 would be affordable for moderate-income individuals. These percentages were calculated assuming a housing expense ratio of 28.0% of gross income for a 5.0% fixed 30 year rate loan. According to Sperling s Best Places, 6 the median home cost in St. Henry was $154,600, which represents a depreciation of 0.8% since the prior year. The median gross rent for the assessment area is $624, with 25.1% of the rents under $500 a month, according to the 2010 U.S. Census. The median gross rent was slightly lower than Ohio s at $678. According to Realtytrac, 7 as of May 2014, foreclosure filings in Ohio were higher than the assessment area. The chart below shows the ratio of properties receiving foreclosure filings in May 2014 for the state of Ohio, the assessment area and the national average. Geography Name Foreclosed Properties in May 2014 Ratio of Properties Receiving Foreclosure Filings in May 2014 Auglaize 24 1:815 Darke 15 1:1,513 Mercer 6 1:2,925 Shelby 12 1:1,681 Ohio 6,250 1:805 United States 110,000 1:1,199 The following table illustrates the demographics of St. Henry s assessment area. 6 Sperling s Best Places, www.bestplaces.net/find/ 7 RealtyTrac, www.realtytrac.com 11
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CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA St. Henry s performance under the lending test is satisfactory. The loan-to-deposit ratio is reasonable and the majority of loans were made inside the bank s assessment area. Although both geographic and borrower distributions were evaluated in order to determine the overall CRA performance, only St. Henry s borrower distribution is discussed in this analysis due to the assessment area having no low- and moderate-income census tracts or distressed or underserved middle-income tracts. The distribution of loans to borrowers reflects a reasonable penetration among individuals of different income levels (including low- and moderate-income) and the distribution of loans to businesses of different income sizes. There were no CRA-related complaints received since the last examination. Loan-to-Deposit Ratio A financial institution s loan-to-deposit (LTD) ratio compares the institution s aggregate loan balances outstanding to its total deposits outstanding. The ratio is a measure of an institution s lending volume relative to its capacity to lend and is derived by adding the quarterly loan-todeposit ratios and dividing the total by the number of quarters. The following table shows St. Henry s quarterly LTD ratios for 17 quarters since the previous evaluation, along with the average LTD ratio for the same period. The same ratios for national peers and customized peers are displayed for the same period. St. Henry Bank Loan-to-Deposit Ratios As of Date St. Henry Bank Aggregate Minster Bank Osgood State First NB in New Custom Peer Ratio Bank Bremen March 31, 2014 58.98 69.16 59.97 55.16 51.53 55.55 December 31, 2013 59.29 71.08 62.88 52.78 50.23 55.30 September 30, 2013 56.98 70.83 59.39 54.61 51.83 55.28 June 30, 2013 56.06 69.85 60.25 54.63 50.15 55.01 March 31, 2013 57.15 67.17 57.18 50.97 49.08 52.41 December 31, 2012 56.46 68.92 61.55 50.19 48.80 53.51 September 30, 2012 57.68 69.99 62.38 49.35 48.78 53.50 June 30, 2012 58.14 70.33 62.13 54.44 49.37 55.31 March 31, 2012 57.55 68.47 61.23 56.55 49.08 55.62 December 31, 2011 62.93 71.39 65.84 54.33 49.51 56.56 September 30, 2011 65.26 72.82 64.37 58.74 49.10 57.40 June 30, 2011 69.28 73.11 65.40 59.06 51.94 58.80 March 31, 2011 70.40 72.13 65.06 57.82 52.56 58.48 December 31, 2010 70.73 74.84 67.20 62.32 52.30 60.61 September 30, 2010 73.65 76.66 68.90 65.18 52.60 62.23 June 30, 2010 76.60 77.19 67.72 71.20 52.43 63.78 March 31, 2010 74.60 76.46 67.84 72.41 53.30 64.52 Quarterly Loan-to-Deposit Ratio Average Since the Previous Evaluation 63.63 71.79 63.49 57.63 50.74 57.29 13
The bank has averaged a quarterly LTD ratio of 63.6% over the past 17 quarters of operation, which is slightly below the aggregate average ratio of 71.8% and above the custom peer average ratio of 57.3%. 8 Over the last 16 quarters, the ratios have decreased, but remained stable over the last eight quarters. St. Henry s LTD ratio is reasonable given the bank s size, financial condition, and assessment area credit needs. Lending in the Assessment Area The following table shows the distribution of loans made inside and outside the bank s assessment area. Lending Inside and Outside the Assessment Area Loan Type - Description Inside Outside Total # % $(000s) % # % $(000s) % # % $(000s) % RL - Residential Loans 143 84.6 21,770 85.6 26 15.4 3,668 14.4 169 100.0 25,438 100.0 XX - Consumer Loans 184 89.3 1,728 87.5 22 10.7 246 12.5 206 100.0 1,975 100.0 Total Consumer-related 327 87.2 23,499 85.7 48 12.8 3,914 14.3 375 100.0 27,413 100.0 SB - Small Business 75 72.1 12,698 36.0 29 27.9 22,536 64.0 104 100.0 35,234 100.0 Total Small Bus.-related 75 72.1 12,698 36.0 29 27.9 22,536 64.0 104 100.0 35,234 100.0 SF - Small Farm 103 81.1 9,997 53.8 24 18.9 8,578 46.2 127 100.0 18,575 100.0 Total Small Farm-related 103 81.1 9,997 53.8 24 18.9 8,578 46.2 127 100.0 18,575 100.0 TOTAL LOANS 505 83.3 46,194 56.9 101 16.7 35,028 43.1 606 100.0 81,222 100.0 The bank s residential mortgage, consumer, small farm, and small business loans were analyzed to determine the volume and amount of lending inside and outside of the bank s assessment area. Of the total loans, 83.3% by volume and 56.9% by dollar amount were made inside the assessment area. Of the residential mortgage loans, 84.6% by volume and 85.6% by dollar amount were made within the bank s assessment area. Additionally, 89.3% by volume and 87.5% by dollar amount were made within the bank s assessment area for consumer loans, followed by small farm lending of 81.1% by volume and 53.8% by dollar amount and small business of 72.1% by volume and 36% by dollar amount. Therefore, a majority of the bank s loans by both volume and dollar amount were made inside the designated assessment area. 8 National peer group consists of all commercial banks having assets between $100 and $300 million in nonmetropolitan areas with three or more full-service offices. 14
Borrower Distribution of Lending St. Henry s lending to borrowers of different income levels and lending to small farms and businesses of different revenue sizes is reasonable. The borrower distribution of consumer lending is excellent, while residential lending is adequate. Lending to small businesses with revenues equal to or under $1 million is good and lending to small farms with revenues equal to or under $1 million is excellent. Residential Lending During the evaluation period, St. Henry s residential lending was compared to the income levels of families in the assessment area (proxy). Borrower income was not known for eight loans; therefore, for the chart below the residential lending numbers were adjusted to exclude the loans where income was unknown. As illustrated in the charts below, lending to low-income families was substantially below proxy. Lending to moderate- and middle-income tracts was similar to proxy and upper-income tracts were above proxy. As previously stated, based on the median family income for the assessment area ($61,604), approximately 32.1% of the homes valued up to $100,412 would be affordable for low-income individuals and 63.2% of the homes valued up to $160,660 would be affordable for moderateincome individuals. Consequently, it may be challenging for these families to qualify for a residential loan, since 5.9% of families and 8.4% of households in the assessment area have incomes below the poverty level. On average, the housing stock of lower-priced homes is typically older than higher-priced homes, making repair costs higher for these properties, which also affects affordability for low-income borrowers. 15
St. Henry s percentage of loans to moderate-, middle-, and upper-income families was similar to or exceeded proxy for other loan categories. Therefore, borrower distribution of residential lending is considered adequate. Small Business Lending There were 75 small business loans originated in the assessment area during the evaluation period totaling $12.7 million. Small businesses are defined as those with gross revenues of less than or equal to $1 million in a calendar year. The gross revenues of some underlying businesses were not known for 26 loans; therefore, for both charts below, the small business numbers were adjusted to exclude loans with unknown revenues. The majority (85.7%) of the remaining loans was originated to businesses with revenues of $1 million or less and was compared to the demographic proxy of 89.7%. 16
According to the data, 88.1% of small business loans were for $100,000 or less and only 7.1% of the loans were for loans from $100,000-$250,000. This reflects the bank s willingness to make smaller dollar loans. Given these factors, the borrower distribution of small business loans is good. Small Farm Lending There were 103 small farm loans originated in the assessment area during the evaluation period totaling $9.9 million. All small farm lending (100.0%) for St. Henry was made to small farms with revenues of $1 million or less as compared to the percentage of small farms (99.5%) in the assessment area. The gross revenues of some underlying businesses were not known for 12 loans; thus, for the chart below, the small farm numbers were adjusted to exclude loans with unknown revenues. 17
Further analysis shows the majority of small farm loans were for $100,000 or less (80.6%). Thus, St. Henry s small farm lending activity is excellent and demonstrates the bank is effectively meeting the credit needs of its community. Consumer Lending The following chart shows the percentage of loans originated to low, moderate, middle, and upper-income borrowers as compared to the household income of the assessment area. Borrower income was not known for 16 loans; therefore, for the chart below the consumer lending numbers were adjusted to exclude the loans where income was unknown. 18
As indicated by the chart, consumer lending in all income categories except upper-income exceeds proxy. Therefore, St. Henry s consumer lending to borrowers of different income levels is excellent and demonstrates a strong commitment to meeting the needs of consumers in the area. Consumer Complaints No CRA-related complaints were filed against St. Henry during the evaluation period. Fair Lending or Other Illegal Credit Practices Review No evidence of discriminatory or other illegal credit practices inconsistent with helping to meet the community s credit needs was identified during this evaluation period. 19
APPENDIX A ASSESSMENT AREA MAP 20
APPENDIX B LENDING TABLES CRA Loan Distribution Table SMALL BUSINESS SMALL FARM Income Categories # % $(000s) % # % $(000s) % By Tract Income Low 0 0.0% 0 0.0% 0 0.0% 0 0.0% Moderate 0 0.0% 0 0.0% 0 0.0% 0 0.0% Low/Moderate Total 0 0.0% 0 0.0% 0 0.0% 0 0.0% Middle 18 24.0% 1,889 14.9% 51 49.5% 6,723 67.3% Upper 57 76.0% 10,809 85.1% 52 50.5% 3,274 32.7% Unknown 0 0.0% 0 0.0% 0 0.0% 0 0.0% Tract Unknown 0 0.0% 0 0.0% 0 0.0% 0 0.0% Total 75 100.0% 12,698 100.0% 103 100.0% 9,997 100.0% By Revenue Total $1 Million or Less 42 56.0% 3,293 25.9% 91 88.3% 7,532 75.3% Over $1 Million 7 9.3% 5,374 42.3% 0 0.0% 0 0.0% Not Known 26 34.7% 4,031 31.7% 12 11.7% 2,465 24.7% Total 75 100.0% 12,698 100.0% 103 100.0% 9,997 100.0% By Loan Size $100,000 or less 50 66.7% 1,856 14.6% 83 80.6% 2,628 26.3% $100,001 - $250,000 12 16.0% 1,973 15.5% 12 11.7% 2,003 20.0% $250,001 - $1 Million (Bus)-$500k 12 16.0% 5,469 43.1% 5 4.9% 1,954 19.5% (Farm) Over $1 Million (Bus)-$500k (Farm) 1 1.3% 3,400 26.8% 3 2.9% 3,412 34.1% Total 75 100.0% 12,698 100.0% 103 100.0% 9,997 100.0% By Loan Size and Revenue $1 Million or Less $100,000 or less 37 88.1% 1,275 38.7% 78 85.7% 2,293 30.4% $100,001 - $250,000 2 4.8% 373 11.3% 8 8.8% 1,373 18.2% $250,001 - $1 Million (Bus)-$500k 3 7.1% 1,645 50.0% 3 3.3% 1,154 15.3% (Farm) Over $1 Million (Bus)-$500k (Farm) 0 0.0% 0 0.0% 2 2.2% 2,712 36.0% Total 42 100.0% 3,293 100.0% 91 100.0% 7,532 100.0% *Information based on 2010 ACS data 21
Consumer Loan Distribution Table CONSUMER LOANS By Tract Income By Borrower Income # % $(000s) % # % $(000s) % Consumer Loans Low 0 0.0% 0 0.0% 47 25.5% 356 20.6% Moderate 0 0.0% 0 0.0% 40 21.7% 356 20.6% Low/Moderate Total 0 0.0% 0 0.0% 87 47.3% 712 41.2% Middle 19 10.3% 237 13.7% 41 22.3% 349 20.2% Upper 165 89.7% 1,491 86.3% 40 21.7% 561 32.4% Unknown 0 0.0% 0 0.0% 16 8.7% 107 6.2% Tract Unknown 0 0.0% 0 0.0% 0 0.0% 0 0.0% Total 184 100.0% 1,728 100.0% 184 100.0% 1,728 100.0% Residential Loans Low 0 0.0% 0 0.0% 3 2.1% 181 0.8% Moderate 0 0.0% 0 0.0% 17 11.9% 1,811 8.3% Low/Moderate Total 0 0.0% 0 0.0% 20 14.0% 1,993 9.2% Middle 37 25.9% 5,318 24.4% 26 18.2% 3,289 15.1% Upper 106 74.1% 16,453 75.6% 89 62.2% 15,656 71.9% Unknown 0 0.0% 0 0.0% 8 5.6% 832 3.8% Tract Unknown 0 0.0% 0 0.0% 0 0.0% 0 0.0% Total 143 100.0% 21,770 100.0% 143 100.0% 21,770 100.0% Consumer Loan Totals Low 0 0.0% 0 0.0% 50 15.3% 538 2.3% Moderate 0 0.0% 0 0.0% 57 17.4% 2,167 9.2% Low/Moderate Total 0 0.0% 0 0.0% 107 32.7% 2,705 11.5% Middle 56 17.1% 5,555 23.6% 67 20.5% 3,638 15.5% Upper 271 82.9% 17,944 76.4% 129 39.4% 16,217 69.0% Unknown 0 0.0% 0 0.0% 24 7.3% 939 4.0% Tract Unknown 0 0.0% 0 0.0% 0 0.0% 0 0.0% Total 327 100.0% 23,499 100.0% 327 100.0% 23,499 100.0% 22
APPENDIX C GLOSSARY OF TERMS Aggregate lending: The number of loans originated and purchased by all reporting lenders in specified income categories as a percentage of the aggregate number of loans originated and purchased by all reporting lenders in the metropolitan area/assessment area. Census tract: A small subdivision of metropolitan and other densely populated counties. Census tract boundaries do not cross county lines; however, they may cross the boundaries of metropolitan statistical areas. Census tracts usually have between 2,500 and 8,000 persons, and their physical size varies widely depending upon population density. Census tracts are designed to be homogeneous with respect to population characteristics, economic status, and living conditions to allow for statistical comparisons. Community development: All Agencies have adopted the following language. Affordable housing (including multifamily rental housing) for low- or moderate-income individuals; community services targeted to low- or moderate-income individuals; activities that promote economic development by financing businesses or farms that meet the size eligibility standards of the Small Business Administration s Development Company or Small Business Investment Company programs (13 CFR 121.301) or have gross annual revenues of $1 million or less; or, activities that revitalize or stabilize low- or moderate-income geographies. Effective September 1, 2005, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation have adopted the following additional language as part of the revitalize or stabilize definition of community development. Activities that revitalize or stabilize: (i) Low-or moderate-income geographies; (ii) Designated disaster areas; or, (iii) Distressed or underserved nonmetropolitan middle-income geographies designated by the Board, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency, based on: a. Rates of poverty, unemployment, and population loss; or b. Population size, density, and dispersion. Activities that revitalize and stabilize geographies designated based on population size, density, and dispersion if they help to meet essential community needs, including needs of low- and moderate-income individuals. Consumer loan(s): A loan(s) to one or more individuals for household, family, or other personal expenditures. A consumer loan does not include a home mortgage, small business, or small farm loan. This definition includes the following categories: motor vehicle loans, credit card loans, home equity loans, other secured consumer loans, and other unsecured consumer loans. 23
Family: Includes a householder and one or more other persons living in the same household who are related to the householder by birth, marriage, or adoption. The number of family households always equals the number of families; however, a family household may also include nonrelatives living with the family. Families are classified by type as either a married-couple family or other family, which is further classified into male householder (a family with a male householder and no wife present) or female householder (a family with a female householder and no husband present). Full-scope review: Performance under the Lending, Investment, and Service Tests is analyzed considering performance context, quantitative factors (for example, geographic distribution, borrower distribution, and total number and dollar amount of investments), and qualitative factors (for example, innovativeness, complexity, and responsiveness). Geography: A census tract delineated by the United States Bureau of the Census in the most recent decennial census. Home Mortgage Disclosure Act (HMDA): The statute that requires certain mortgage lenders that do business or have banking offices in a metropolitan statistical area to file annual summary reports of their mortgage lending activity. The reports include such data as the race, gender, and the income of applications, the amount of loan requested, and the disposition of the application (for example, approved, denied, and withdrawn). Home mortgage loans: Includes home purchase and home improvement loans as defined in the HMDA regulation. This definition also includes multifamily (five or more families) dwelling loans, loans for the purchase of manufactured homes and refinancing of home improvement and home purchase loans. Household: Includes all persons occupying a housing unit. Persons not living in households are classified as living in group quarters. In 100 percent tabulations, the count of households always equals the count of occupied housing units. Limited-scope review: Performance under the Lending, Investment, and Service Tests is analyzed using only quantitative factors (for example, geographic distribution, borrower distribution, total number and dollar amount of investments and branch distribution). Low-income: Individual income that is less than 50 percent of the area median income, or a median family income that is less than 50 percent, in the case of geography. Market share: The number of loans originated and purchased by the institution as a percentage of the aggregate number of loans originated and purchased by all reporting lenders in the metropolitan area/assessment area. 24
Metropolitan area (MA): A metropolitan statistical area (MSA) or a metropolitan division (MD) as defined by the Office of Management and Budget. A MSA is a core area containing at least one urbanized area of 50,000 or more inhabitants, together with adjacent communities having a high degree of economic and social integration with that core. A MD is a division of a MSA based on specific criteria including commuting patterns. Only a MSA that has a population of at least 2.5 million may be divided into MDs. Middle-income: Individual income that is at least 80 percent and less than 120 percent of the area median income, or a median family income that is at least 80 percent and less than 120 percent, in the case of geography. Moderate-income: Individual income that is at least 50 percent and less than 80 percent of the area median income, or a median family income that is at least 50 percent and less than 80 percent, in the case of geography. Multifamily: Refers to a residential structure that contains five or more units. Other products: Includes any unreported optional category of loans for which the institution collects and maintains data for consideration during a CRA examination. Examples of such activity include consumer loans and other loan data an institution may provide concerning its lending performance. Owner-occupied units: Includes units occupied by the owner or co-owner, even if the unit has not been fully paid for or is mortgaged. Qualified investment: A qualified investment is defined as any lawful investment, deposit, membership share, or grant that has as its primary purpose community development. Rated area: A rated area is a state or multistate metropolitan area. For an institution with domestic branches in only one state, the institution s CRA rating would be the state rating. If an institution maintains domestic branches in more than one state, the institution will receive a rating for each state in which those branches are located. If an institution maintains domestic branches in two or more states within a multistate metropolitan area, the institution will receive a rating for the multistate metropolitan area. Small loan(s) to business(es): A loan included in 'loans to small businesses' as defined in the Consolidated Report of Condition and Income (Call Report) and the Thrift Financial Reporting (TFR) instructions. These loans have original amounts of $1 million or less and typically are either secured by nonfarm or nonresidential real estate or are classified as commercial and industrial loans. However, thrift institutions may also exercise the option to report loans secured by nonfarm residential real estate as small business loans if the loans are reported on the TFR as nonmortgage, commercial loans. 25
Small loan(s) to farm(s): A loan included in loans to small farms as defined in the instructions for preparation of the Consolidated Report of Condition and Income (Call Report). These loans have original amounts of $500,000 or less and are either secured by farmland, or are classified as loans to finance agricultural production and other loans to farmers. Upper-income: Individual income that is more than 120 percent of the area median income, or a median family income that is more than 120 percent, in the case of geography. 26